comprised of citizen members and staff who concerned with the
management activities, including the hazing and slaughtering, of
Yellowstone's wild buffalo herd by the MDOL and other State and Federal
agencies. CMCR is also a news organization whose purposes and activities
include data-gathering and distribution of information to its members and
the public in general. As part of its work, CMCR has been seeking
information, on behalf itself and CoPetitioners, from the Montana
Department of Livestock about buffalo management, helicopter and other
methods of buffalo hazing, including times and places of hazing, and
brucellosis testing, among other information. CMCR, like the other
Petitioners, has consistently and systematically been denied access to
public information, and has at various other times, been provided
The preceding paragraphs are realleged as though set forth in
Jurisdiction is proper in that Petitioners seek a Writ of
Mandamus pursuant to §27-26-101, et seq., MCA. The Montana Department
of Livestock has a clear legal duty under the Montana Constitution and
statutes to provide the information requested, and there is no "plain,
speedy or adequate remedy in the ordinary course of law."
102, MCA. Petitioners have provided the affidavit of Darrell Geist,
Executive Director of Petitioner Cold Mountain, Cold Rivers, in accordance
